Randy Lee Guzek

Case identification

Randy Lee Guzek was sentenced to death in 1988.

Background

In Oregon v. Guzek, 546 U.S. 517 (2006), the Supreme Court of the United States ruled that the Eighth Amendment to the United States Constitution did not grant criminal defendants facing the death penalty the right to introduce new evidence of their innocence during sentencing that had not been introduced during trial. The Supreme Court stated that states could constitutionally exclude such evidence from the sentencing phase of a capital trial.

Timeline

• 1988 — Randy Lee Guzek was sentenced to death.
• 2006 — Oregon v. Guzek, 546 U.S. 517 (2006), was decided by the Supreme Court of the United States.

Appeals

First state appeal

Randy Lee Guzek was convicted of murder and sentenced to death. On appeal, the Oregon Supreme Court affirmed his conviction but vacated the sentence. The Oregon Supreme Court ruled that the death sentence violated the Eighth Amendment because the jury was not presented with a “general mitigation question,” which would ensure that it had the opportunity to give effect to any relevant mitigating evidence outside of the statutory factors that were submitted to it. The Oregon Supreme Court remanded the case back to the trial court for a new sentencing trial.

Second state appeal

On remand, Guzek was sentenced to death again. He appealed, and the Oregon Supreme Court again vacated the sentence. The Oregon Supreme Court ruled that “victim impact” evidence that the State had presented during sentencing was not relevant, and so unconstitutionally secured the death sentence. The Oregon Supreme Court remanded the case for a third sentencing trial.

Third state appeal

During the third sentencing trial, the trial judge failed to instruct the jury about a “true-life” sentencing option—life in prison without the possibility of parole—as an alternative to the death penalty. Guzek was once again sentenced to death. Based on this error, the Oregon Supreme Court once again vacated Guzek’s sentence and remanded for a new sentencing trial.

In addressing the fourth sentencing proceeding, the Oregon Supreme Court also addressed the exclusion of alibi evidence that Guzek had sought to admit. The alibi evidence consisted of transcripts of testimony by his mother and grandfather stating he was with them at the time of the murder. The Oregon Supreme Court ruled that under state law and the Eighth Amendment, Guzek had a right to present this evidence during his death penalty sentencing. The Oregon Supreme Court directed the trial court to admit all alibi evidence he submitted.

The State of Oregon then petitioned the Supreme Court for review.

The Supreme Court’s decision

The United States Supreme Court unanimously reversed the Oregon Supreme Court. The Supreme Court ruled that the Eighth Amendment’s prohibition against cruel and unusual punishment did not create a right to introduce evidence of innocence in a defendant’s death penalty sentencing phase if it had not been introduced in the trial phase. The Supreme Court ruled that states were instead permitted by the U.S. Constitution to limit such evidence to that which was already presented at trial.

Guzek had argued that the alibi evidence could be used to impeach the testimony of other witnesses. The Supreme Court left open to the Oregon Supreme Court on remand the question of whether this use was permissible under Oregon law.

Other details

The Supreme Court’s ruling in Oregon v. Guzek concerned whether the Eighth Amendment allowed new evidence of innocence to be introduced during sentencing in capital cases when it had not been introduced during trial.